SecProbe.io

United States securities and exchange commission logo
July 28, 2020
Richard P. Dealy
Executive Vice President and Chief Financial Officer
Pioneer Natural Resources Company
777 Hidden Ridge
Irving, Texas 75038
Re:Pioneer Natural Resources Company
Form 10-K for the Fiscal Year Ended December 31, 2019
10-K filed February 24, 2020
File No. 001-13245
Dear Mr. Dealy:
            We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2019
Properties
Drilling Activities, page 42
1.Expand the disclosure of your drilling activities to clarify the extent, if true, that your
productive exploratory wells include wells drilled to extend the limits of a known
reservoir, e.g. extension wells.  Refer to the definition of a productive well in Item
1205(b)(2) of Regulation S-K and the definitions of a development, exploratory and
extension well in Rule 4-10(a)(9), (a)(13) and (a)(14), respectively.
Unaudited Supplementary Information
Oil & Gas Exploration and Production Activities
Reserve Quantity Information, page 108
2.The change in the net quantities of total proved reserves attributed to extensions and

 FirstName LastNameRichard P. Dealy
 Comapany NamePioneer Natural Resources Company
 July 28, 2020 Page 2
 FirstName LastName
Richard P. Dealy
Pioneer Natural Resources Company
July 28, 2020
Page 2
discoveries appears to be significantly greater than the corresponding change in the net
quantities of proved undeveloped reserves for each of the last three fiscal years presented.
Expand the discussion of the changes in your total proved reserves attributed to extensions
and discoveries to explain the reason(s) for this difference.  Refer to FASB ASC 932-235-
50-5.
3.Expand the tabular disclosure of your proved reserves to present the net quantities of
proved developed and proved undeveloped reserves, by individual product type, at the
beginning of 2017, the first period presented in the reserves reconciliation.  Refer to
FASB ASC 932-235-50-4.
4.The future production and development costs shown on page 111 in the tabular
presentation of the cash flows from proved undeveloped reserves as of December 31,
2019 appear to be significantly less than the corresponding production costs in the
standardized measure as of December 31, 2019 and the development costs incurred to
convert proved undeveloped reserves during fiscal 2019, when determined on a dollar per
Boe of reserves basis.

For example, the future production costs for proved undeveloped reserves of $638 million
correlates to $11.07 per Boe; however, the future production costs for total proved
reserves of $19,687 million correlates to $17.34 per Boe of reserves.  Similarly, the future
development costs for proved undeveloped reserves of $508 million correlates to $8.81
per Boe; however, the costs incurred to convert proved undeveloped reserves during fiscal
2019 of $743 million correlates to $27.58 per Boe of reserves.

Expand your disclosure of the future cash flows from proved undeveloped reserves as of
December 31, 2019 to explain the reason(s) for the differences in future production costs
compared to the costs used to determine the cash flows for total proved reserves and for
the differences in future development costs compared to the costs incurred to convert
proved undeveloped reserves during the last fiscal year.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact John Hodgin, Petroleum Engineer, at (202) 551-3699 if you have
questions regarding the engineering comments.  Please contact Brad Skinner, Office Chief, at
(202) 551-3489 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation